Your personal data is stored and processed in the United States, even if you are in a country with stronger privacy laws such as those in the EU or UK.
This analysis describes what Coursera's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
EU, UK, and other non-U.S. users should be aware that their data is transferred to a jurisdiction with a different legal framework, and the adequacy of transfer mechanisms is a material compliance consideration.
Interpretive note: The specific transfer mechanism (SCCs, DPF, or other) is not identified in the document, creating uncertainty about the legal basis for EU/UK to U.S. transfers.
The updated terms now explicitly disclose that Coursera processes communications through voice-enabled features that transcribe audio into text, and clarify that personal data may be shared with third parties including affiliates and business partners. The policy expands descriptions of AI-driven personalization and chatbot applications that use your learning and interaction data. The terms establish that data may be transferred to entities that become Coursera affiliates or subsidiaries during business transitions. You should review the updated guidance that cautions against including unnecessary or sensitive personal data in the platform's free-text and voice-enabled communication features.
View change record →The updated Privacy Notice removes explicit language stating that the policy does not apply to Coursera's Ollie mobile application and no longer directs users to a separate Ollie Privacy Notice for that app. Previously, users of Ollie had clear notice to consult a dedicated privacy policy; that direction is now absent from the main Privacy Notice. The updated notice also narrows the scope of covered entities by removing 'affiliates' from the definition of Coursera, stating the policy now applies to Coursera, Inc., its subsidiaries, and international branches only. Users of the Ollie App should independently verify what privacy terms currently govern that application, as the main Coursera Privacy Notice no longer explicitly addresses Ollie coverage.
View change record →Non-U.S. users' personal data is transferred to and processed in the United States, which may involve reduced statutory protections compared to their home jurisdiction, depending on the transfer mechanism Coursera employs.
How other platforms handle this
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers and partners operate. By using our Services, you acknowledge that your personal information may be transferred to countries outside your country of residence, in...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"Coursera is a U.S.-based company and your personal data will be processed in the United States. If you are located outside the United States, the data protection laws of the United States may differ from those in your country.— Excerpt from Coursera's Coursera Privacy Notice
REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (international data transfers), the UK GDPR equivalent transfer rules, and any applicable adequacy decisions or standard contractual clauses (SCCs) required to legitimize transfers from the EU/EEA and UK to the U.S. The EU-U.S. Data Privacy Framework (DPF) may be relevant if Coursera is certified. EU supervisory authorities and the UK ICO are the primary enforcement bodies. GOVERNANCE EXPOSURE: Medium. The notice acknowledges the transfer but does not specify the transfer mechanism employed (SCCs, DPF certification, or binding corporate rules). Absence of explicit mechanism disclosure may create transparency gaps under GDPR Articles 13 and 14, which require disclosure of the transfer safeguards at the time of data collection. JURISDICTION FLAGS: EU/EEA and UK users face heightened exposure if the transfer mechanism is not current or adequately documented. Following the Schrems II ruling and subsequent developments, reliance on SCCs requires a transfer impact assessment. Organizations in the EU and UK that use Coursera as a vendor should verify current transfer mechanism documentation. CONTRACT AND VENDOR IMPLICATIONS: Enterprise clients in the EU or UK should request and review Coursera's current data transfer mechanism documentation, including SCCs or DPF certification status, as part of vendor due diligence. Data processing agreements should specify the legal basis for international transfers. COMPLIANCE CONSIDERATIONS: Legal teams should confirm whether Coursera maintains current SCCs or DPF certification, request transfer impact assessments where required, and ensure that data processing agreements with Coursera reflect the current state of international transfer law.
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EU, UK, and other non-U.S. users should be aware that their data is transferred to a jurisdiction with a different legal framework, and the adequacy of transfer mechanisms is a material compliance consideration.
Non-U.S. users' personal data is transferred to and processed in the United States, which may involve reduced statutory protections compared to their home jurisdiction, depending on the transfer mechanism Coursera employs.
ConductAtlas has identified this type of provision across 84 platforms. See the full comparison.
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